Privacy Policy for MyRinkya

Last Updated on 25 May 2018. This Privacy Policy is effective immediately for users that sign up for Rinkya accounts on or after 25 May 2018 and will become effective on 25 May 2018 for users that already have Rinkya accounts. To review the previous policy, please see above.
This Privacy Policy describes our policies on the collection, use, and disclosure of information about you in connection with your use of our services, including those offered through our websites, emails, and mobile applications (collectively, the "Service"). The terms "we", "us", and "Rinkya" refer to Rinkya Inc., a company incorporated in Arizona. When you use the Service, you acknowledge our collection, use, and disclosure of information about you as described in this Privacy Policy.

1. INFORMATION WE COLLECT AND HOW WE USE IT
We may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service. We use that information to provide the Service’s functionality, fulfill your requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service, provide feedback to third party businesses that are listed on the Service, display relevant advertising, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.
Please also note:
* a. Account Information: If you create a Rinkya account, we may store and use the information you provide during that process, such as your full name, email address, zip code, physical address, and other information you may provide with your account, such as your gender, phone number, and birth date. We may publicly display your first name and last initial, as well as any photo or other content you submit through the registration process, as part of your account profile. You can modify some of the information associated with your account through your Account Settings under your Member Profile here: https://www.rinkya.com/en/user/profile If you believe that someone has created an unauthorized account depicting you or your likeness, you can request its removal by flagging it and contacting us at needhelp?@rinkya.com
* b. Public Content: Your contributions to the Rinkya service are held in private and are not available for public viewing unless they are blog comments, item reviews, forum posts.
* c. Contacts: You can invite others to join or become your friend on Rinkya by providing us with their contact information, or by allowing us to access your contacts from your computer, mobile device, or third party sites to select which individuals you want to invite. If you allow us to access your contacts, we may transmit that information to our servers long enough to process your invitations.
* d. Communications: When you sign up for an account or use certain features, you are opting to receive messages from Rinkya only. You can manage some of Rinkya communications through your Member profile https://www.rinkya.com/en/user/profile or by unsubscribing to our mailing list. Please note that you cannot opt out of receiving certain administrative, transactional, or legal messages from Rinkya. For example, if place an item on your watchlist, ask to receive alerts about certain keywords, categories or sellers, place yourself on a waitlist, or request a quote from a business through the Service, we may send you messages about your transaction using the contact information you provide, including through automated SMS text messages to your phone number. We may also track your actions in response to the messages you receive from us or through the Service, such as whether you deleted, opened, or forwarded such messages. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests to exchange reviews for compensation. If you send or receive messages through the Service via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business listed on Rinkya, we may contact you, including by phone or email, using the contact information you provide us, make publicly available, or that we have on record for your business. Our calls with you may be monitored and recorded for quality purposes.
* e. Transactions: If you initiate a transaction through the Service, such as a bid or store purchase, we may collect and store information about you, such as your name, phone number, address, email, and payment information (such as a credit card number and expiration date), as well as any other information you provide to us, in order to process your transaction, send communications about them to you, and populate forms for future transactions. This information will NOT be shared with third parties. When you submit credit card numbers, we encrypt that information using industry standard technology. If you write reviews about sellers with which you transact through the Service, we may publicly display the fact that you transacted with those sellers. For example, if you win an item or purchase an item through the Service and write a review about your experience, we may publicly display the fact that you made your purchase through the Service.
* f. Activity: We may store information about your use of the Service, such as your search activity, the pages you view, the date and time of your visit, businesses you call using our mobile applications, and purchases you make through the Service. We also may store information that your computer or mobile device may provide to us in connection with your use of the Service, such as your browser type, type of computer or mobile device, browser language, IP address, WiFi information such as SSID, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location), and requested and referring URLs. We may also receive and store your location whenever our mobile applications are running, including when running in the background, if you enable our mobile apps to access such information in the course of using the Service. You may be able to limit or disallow our use of certain location data through your device or browser settings, for example by adjusting the “Location Services” settings for our applications in iOS privacy settings.
* g. Different Devices: You may access the Service through different devices (e.g., your mobile phone or desktop computer) and different platforms (e.g., the Rinkya website or Rinkya mobile app). The information that we collect and store through those different uses may be cross-referenced and combined, and your contributions through one Rinkya platform will typically be similarly visible and accessible through all other Rinkya platforms.
* h. Legal Basis for Processing: For residents of the European Economic Area (EEA) and Switzerland only, our legal basis for collecting and using the information described above will depend on the specific information concerned and the context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for instance, to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations). If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate our Services, communicate with you in relation to our Services, or for our other legitimate commercial interests, for instance, when responding to your queries, to analyze and improve our platform, engage in marketing, or for the purposes of detecting or preventing fraud. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the address listed below in the “Contact” section.

2. COOKIES
We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called "flash cookies"), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology ("Cookies") in connection with your use of the Service, third party websites, and mobile applications. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
The purposes for which we use Cookies in the Service include:

Purpose ExplanationProcesses Intended to make the Service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.

Authentication, Security, and Compliance Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in.

Preferences Intended to remember information about how you prefer the Service to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications to your phone.
Notifications Intended to allow or prevent notices of information or options that we think could improve your use of the Service. For example, we use a Cookie that stops us from showing you the signup notification if you have already seen it.

Advertising Intended to make advertising more relevant to users and more valuable to advertisers. For example, we may use Cookies to serve you interest-based ads, such as ads that are displayed to you based on your visits to other websites, or to tell us if you have recently clicked on an ad.

Analytics Intended to help us understand how visitors use the Service. For example, we use a Cookie that tells us how our search suggestions correlate to your interactions with the search page.
You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Service. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. For flash cookies, you can manage your privacy settings by clicking here. Please note that changing any of these settings does not prevent the display of certain advertisements to you.

3. THIRD PARTIES
Third parties may receive information about you as follows:
* a. Advertisers: We may allow third parties to use Cookies through the Service to collect the same type of information for the same purposes as we do. In doing so, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have access to or control over the Cookies they use, but you may be able to opt out of some of their practices by visiting the following links: Network Advertising Initiative, Omniture, Digital Advertising Alliance and PrivacyChoice. Please note that opting out does not prevent the display of all advertisements to you. Additionally, we may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address) to facilitate the display of targeted advertising. You may be able to limit our sharing of some of this information through your mobile device settings, as described in Section 2 above, or through the Service’s settings.
* b. Content Partners: We DONOT allow third party partners to use and display some of the public content available through the Service, such as your photos, purchases, and other information detailed in Section 1(b) above.
* c. Service Providers: We may rely on third party providers to support or provide some of the services that are available through the Service, such as KYC and communications. We may also rely on third party providers to perform certain services for us in connection with your use of the Service, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, our own marketing of the Service, and other functions. We may share information from or about you with these third party providers so that they can perform their services or complete your requests. These third party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third party providers may also share this information with their subsidiaries, joint ventures, or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third party providers, while preserving the look and feel of the Service. In such cases, please note that the information you provide is being provided to the third party.
* d. Aggregate or Anonymous Information: We may share user information in the aggregate with third parties, such as businesses that are listed on Rinkya and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements. We may also disclose anonymized information about your use on Rinkya, for example if you engage in a transaction in connection with Rinkya, we may publicly disclose information about the transaction without providing identifying information about you or otherwise disclosing your participation in the transaction.
* e. Business Transfers: We may share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. If another company acquires Rinkya, or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.
* f. Businesses on Rinkya: We may share information from or about you (such as your age and gender), your devices, and your use of the Service (such as which businesses you bookmark or call) with businesses listed on Rinkya. You may adjust your account settings to increase or decrease the amount of information we share. Keep in mind that businesses may still see your public activity and posts, and may receive information from or about you when you transact or communicate with them, through Rinkya or otherwise, regardless of your settings (see Section 1 above). Additionally, if you make a phone call to a business through or in connection with your use of the Service, we may share information about your call with the business that the business would have received had you called them directly, such as the date and time of your call and your phone number. You may be able to limit our ability to collect and share your phone number through your phone’s settings or phone service provider.
* g. Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement requests served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public. If you flag or otherwise complain to us about content through the Service, we may share the substance of your complaint with the contributor of that content in order to provide an opportunity for the contributor to respond.
* h. Links: The Service may link to third party services, like a business’s URL. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on or applicable to all such third party services.
* i. Third Party Accounts: If you sign up for, or log into, Rinkya using a third party service like Facebook or Google, or link your Rinkya account to your account with a third party service like Facebook or Twitter, we may receive information about you from such third party service. If you post content to a third party service through the Service, that third party service will also receive that content, which will be visible to anyone that has access to it through that third party service.

4. CONTROLLING YOUR PERSONAL DATA
Other users may be able to identify you, or associate you with your account, if you include personal information in the content you post publicly. Rinkya anonymizes your bidding ID and unless you publicly indicate this is you, we do not let other users know. You can reduce the risk of being personally identified by using the Service pseudonymously, though doing so could detract from the credibility of your contributions to the Service. Please also note that the messages you send or receive using the Service are only private to the extent that both you and the person you are communicating with keep them private. For example, if you send a message to another user, that user may choose to publicly post it. Also, we may access and disclose such messages in the course of investigations relating to use of the Service.
If you are a resident of the EEA or Switzerland, you have the right to access, correct, update or request deletion of your personal information. You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You also have the right to opt-out of marketing communications we send you at any time. The Service generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. However, if you have any questions or concerns about the processing of your personal information, you may contact us as outlined in the “Contact” section below. Please note that Rinkya Inc., a limited liability company established and resident under the laws of Arizona, The United States, is the “data controller” responsible for protecting your personal data related to the Service.

5. DATA RETENTION AND ACCOUNT TERMINATION
You can close your account by contacting us directly at needhelp?@rinkya.com. We will remove certain public posts from view and/or dissociate them from your account profile, but we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. Please note that businesses cannot remove their business listings, ratings, or reviews by closing their accounts.

6. CHILDREN
The Service is intended for general audiences and is not directed to children under 18. We do not knowingly collect personal information from children under 18 resident in the EEA or Switzerland. If you become aware that such a child has provided us with personal information without parental consent, please contact us needhelp?@rinkya.comIf we become aware that such a child under 18 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child's account.

7. SECURITY
We use appropriate technical and organizational security measures to protect the personal information submitted to us from accidental or unlawful destruction, loss, alteration and unauthorised disclosure or access, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will take such steps as we deem necessary to confirm your identity before sharing any personal data with you. We will respond to proper and confirmed requests relating to personal data within 30 days, or as otherwise required by applicable law.

9. MODIFICATIONS TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you and will be located here: https://www.rinkya.com/en/page/terms-of-service. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on the Service prior to the effective date of the changes. By continuing to access or use the Service after those changes become effective, you acknowledge the revised Privacy Policy.

10. INTERNATIONAL DATA TRANSFER
For residents of the EEA or Switzerland, please note that the personal data information we obtain from or about you may be transferred, processed and stored outside of the EEA or Switzerland for the purposes described in this Privacy Policy, including in the United States of America. We take the privacy of our users seriously and therefore take steps to safeguard your information, including assuring an adequate level of data protection in accordance with E.U. standards. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection laws. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.